ML20216G262
| ML20216G262 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/04/1998 |
| From: | Gordon Peterson DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-413-97-300, 50-414-97-300, NUDOCS 9803190313 | |
| Download: ML20216G262 (6) | |
Text
..
Duke Power Company A [ hoke Ewy Cmny
~
b Catawba Nudear Station d r** s sr %
4800 Concord Road York SC29745 Ga,y R. Peterson (803) 831-4251 omCE Vice i+rsident (803) 831-3426ux March 4, 1998 U.
S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555-0001
Subject:
Duke Energy Corporation Catawba Nuclear Station Dockets 50-413 and 50-414 Reply to Notice of Violation (NOV)
Inspection Report 50-413, 414/97-300 Pursuant to the provisions of 10 CFR 2.201, attached is Duke Energy Corporation's response to a Notice of Violation dated February 2, 1998.
Inspection Report 50-413, 414/97-300 identifies two Level IV violations regarding: 1) exceeding the operator training cycle of 24 months and, 2) the use of security personnel in performing non-licensed operator emergency tasks.
These violations were identified during inspections conducted between November 17-19, 1997 and December 1-19, 1997.
Duke Energy Corporation acknowledges the first occurrence to be a violation of the requirements of 10 CFR 55.59 (a) (1) and denies the second occurrence to be in violation of 10 CFR 50.120(b) respectively.
Commitments are listed under Corrective Actions to be Taken in the responses to these violations.
If there are any questions concerning this response, please
[
contact M.
S. Purser at (803) 831-4015.
I Since ely,
'l
{
)i s
" G. ~ R[ Peterson
~"'{g;zg.C
.g
,' [ ]/[/3 h/d C ff h b b b
/
/
Attachment 2
,V 9003190313 900304 "
1 U.'S.
Nuclear Regulatory Commission March 4,-1998 Page 2 xc:
Mr. Luis A.
Reyes Regional Administrator, Region II U.S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth St.,
Suite 23T85 Atlanta, Georgia 30303 P.
S. Tam U.S.
Nuclear Regulatory Commission Senior Project Manager Office of Nuclear Reactor Regulation One White Flint North, Mail Stop O-14H25 Washington, D. C.
20555-0001 D.
J.
Roberts U.
S.
Nuclear Regulatory Commission Senior Resident Inspector Catawba Nuclear Station j
l i
)
i
(
~
i
2 Catawba Nuclear Station Reply to Notice of Violation Statement of Violation 50-413,414/97-300-01 10 CFR 55.59 (a) (1), Requalification Requirements, requires, in part, that each (operator) licensee successfully complete a requalification program developed by the facility licensee.
It also requires the program be conducted for a continuous period (cycle) not to exceed 24 months duration.
Additionally, 10 CFR 55.59 (c) (4), Requalification Evaluation, requires, in part, that'the requalification program include comprehensive written examinations and annual operating tests.
These requirements were implemented by Duke Power Catawba Operations Training Procedure OTMP 3.0, Revision 7.
Contrary to the above, between January 1991 and December 1996, the comprehensive, biennial written and annual operating tests, which should have been administered during each of the three 24 month requalification cycles, were actually conducted between three and eleven months after completion of the requalification cycle.
This is a Severity Level IV violation.
Reply to Violation 50-413,414/97-300-01 Reason for Violation Duke Energy Corporation acknowledges this violation.
This violation is attributed to the misinterpretation of: 1) the requirement to conduct the comprehensive written examination within the defined 24 month continuous cycle and the annual operating examination within the utility defined 12 month requalification year, and; 2) the one time annual operating examination schedule change approved by the NRC in 1994.
Catawba interpreted the provision for the comprehensive written examination as requiring a continuous training program for 24 months followed by a comprehensive written examination that
. included an evaluation of the previous 24 months of training.
The requirement was similarly interpreted for the annual operating examination as requiring 12 months of continuous
' training followed by an annual operating examination.
Additionally, an exam schedule change was approved by the NRC in 1994 to allow Catawba Nuclear Station to move the 1994 annual
~
-operating-examination from April 1994 to September 1994. It was not recognized that this approval only applied to the 1994
schedule.
Thereforc, Catawba did not return to the original schedule of examining in the April time frame but continued on the September examination schedule through 1997.
Corrective Actions Taken and Results Achieved L
An evaluation of the exam results indicated no negative impact as a result of delayed testing.
Corrective Action to be Taken to Avoid Future Violations The 1997/1998 requalification program comprehensive written examination and the annual operating examination will be completed by December 31, 1998.
The Operations Training Management Procedures (OTMP) will be revised to specify completion of the comprehensive written
- examination within the 24 month cycle and as close to the end of the 24 month cycle as can be scheduled.
The OTMP will be revised to specify completion of an annual operating examination within the first 12 months and within the second 12 months of the 24 month cycle.
The OTMP will specify that the annual operating examinations should be conducted as close to the end of each 12 month period as can be scheduled.
Datn of Full Comoliance Catawba Operations Training will reschedule the training segments for the remainder of 1998 to-include the written and operator exams, thereby bringing Catawba back into full compliance by December 31,1998.
,0 Statement of Violation 50-413,414/97-300-04 10 CFR 50.120(b), Training and Qualification of Nuclear Power Plant Personnel Requirements, as implemented by Catawba Operator Training Management Procedure, " Design and Development" -(OTMP 3.0), requires licensees to establish, implement and maintain a training program derived from a systems approach to training as defined in 10 CFR 55.4 for non-licensed. operators.
Element (5) of the systems approach to training requires evaluation and revision of the training based on the performance of trained personnel in the job setting.
Contrary to the above, as of December 19, 1997, selected officers from the site security force had been trained to perform the non-licensed operator emergency tasks for starting and operating the Safe Shutdown Facility (SSF) diesel generator and had not been retrained nor had their performance evaluated since initial
-training and testing in December, 1996.
When tested in December,
~1997, four of seven security force SSF Operators failed all or j
part of thei r written and walkthrough examinations.
This is a Severity Level IV violation.
Reply to Violation 50-413,414/97-300-04 Reason for Denial of Violation Duke Energy Corporation denies this violation, 10 CFR 50.120(b) states in part that the training program must incorporate the instructional requirements to train personnel, and, provide for
)
periodic evaluation of the program for changes and periodic review of the program by management for effectiveness.
These requirements are met at Catawba by utilizing the Systems Approach to Training.
An effectiveness review clearly implies that a licensee may find an existing training program to require modification.
' Administration of the written and walkthrough examinations which led to the failure of 4 of 7 security force SSF operators was q
done in conformance to 10 CFR 50.120 (b).
It is not a violation of this regulation to have a failure of an examination.
In this case, all officers have now been retrained, and changes have already been made to this training program.
Duke's compliance with 10 CFR.50.120 (b) led the licensee.to discover the need to enhance its existing security force SSF operator training program, all as contemplated by the rule; therefore, the licensee
'does not believe a1 violation of the rale has taken place.
The systems approach to training was followed throughout the process of1 evaluating the security officers initial and continuing training needs.
fc
,j Q
In Dedember of 1996, discussions were held between security, operations and operations training to discuss the possibility of training security officers to start and run the SSF diesel generator during an event requiring its operation.
Security officers were already manning the SSF as part of the Catawba Security Plan.
A job task analysis was conducted as part of the systems approach to training.
From the analysis, specific tasks were identified that the security officers would be required to perform.
Training materials were developed that would provide the officers with the needed knowledge and skills required to perform the tasks.
Specifically, training was conducted for the following systems and administrative controls:
Component Cooling Chemical Volume Control Standby Shutdown Facility Reactor Coolant Pumps Reactor Coolant Six Tools Trainer Communications systems Valve and Breakers Appropriate Site Directives A special qualification (S0) task was developed that specifically outlined what the officers would be required to perform.
Initial classroom training was completed and the officers passed a written examination and qualified to the task by receiving in-field training by qualified trainers.
A training evaluator conducted the evaluation of the officers' ability to perform the task unsupervised. The officers were ' qualified' to stand SSF watch once the evaluation was passed.
Initial discussions indicated that the security officers would be re-evaluated for these tasks in approximately one year (December 1997).
This decision was made based in part on the fact that the officers would need to be re-evaluated on a more frequent basis than the operations personnel.
Operators are presented the same material on a frequency of approximately 2 years.
It was concluded that it was reasonable to believe that the officers would retain the necessary knowledge and skills for a one year period.
Based on the results of the year-end testing, the training was to be modified as necessary as part of the system approach to training.
l After four of seven security officers failed the annual examinations, all qualified security officers were given refresher-classroom training on the systems / topics listed above.
Also included was a generic lesson on effective ' test taking'
)
)
.y
.a
)
skills.
After the refresher training was concluded, all the qualified security officers were administered another examination-(including the four that had failed).
All the officers successfully passed the written examination.
Per the systems approach to training, and after year-end evaluation, Catw.ca determined that more freqaent training on SSF operations was needed for the security officere.
Conservatively, operations training will be conducting quarterly training beginning in March 1998.
Classroom and in-field training will be followed by an examination.
An evaluation of the quarterly results will be performed and program changes will be made based on the'results of the examination.
The first quarter training will be a ' cold' evaluation.
This evaluation will be conducted without refresher training to better gauge the security officers retention factor with respect to SSF operation.
Following this evaluation, operations training will provide the security officers with the necessary refresher training based on results
-of the ' cold' evaluation.
In the fourth quarter of 1998, a comprehensive exam will be administered at which time the training program will once again be re-evaluated and modifications made as necessary.
Based on the results of the comprehensive exam the training cycle may be lengthened as deemed appropriate.
The above discussion outlines a systems approach to training.
The point of contention is the length of time between initial qualifications of the security officers and their re-evaluation.
Although the review clarified that more frequent refresher training is needed for the officers, the initial plan brought the security officers back for re-evaluation in half the time required of the non-licensed operators.
It should also be noted that although the security officer manning the SSF is, and will continue to be, the first responder
-to an event, qualified operators are still being dispatched to the SSF.
Corrective Action Taken and Results Achieved None 1
1 Corrective Actions to be Taken to Avoid Future Violations None Date of Full Compliance Duke Energy Corporation has been and continues to be in full
)
compliance.
l J